The Resolution of Election Disputes: Legal Principles that Control Election Challenges vote buying on behalf of Ms. Curtis at the Fountain Run Precinct, that the results at the precinct were far out of line with usual election results there and that the vote buying there was common knowledge. Accordingly, the court of appeals decided that “…the election in Fountain Run was so tainted with fraud” that, following Kentucky law, it voided the results of the Fountain Run Precinct and, on the basis of the rest of the votes cast in the county, ordered the lower court to declare that Patsy Jernigan was the Republican nominee for the office of circuit court clerk in Monroe County. A different result was reached in Nugent v. Phelps, 816 So.2d 349, 357 (La. Ct. App. 2002), where vote buying did not work. Even though there was a vote-buying scheme, and people who voted received something of value, the votes cast by people whose choice of candidate was not affected by the scheme were counted for the candidates they chose, including the candidate who sponsored the vote-buying scheme. • Robert “Lip” Hall, Jr., asked voters to vote for candidates two and four. Lip was working for a candidate for police chief, Benji Phelps (number four on the ballot; the mayor was number two). Afterwards, Lip took those voters to a convenience store to get cigarettes and beer, paid for out of the $100 account, known as “Benji’s account,” which had been set up by Benji Phelps. Phelps won the election by four votes. Six voters testified that they got a piece of paper from Lip or were told by him to vote for Mr. Phelps and got beer and/or cigarettes; a seventh voter said she was promised $5 by Lip. Two voters voted as instructed by Lip. The other five voters took the beer or cigarettes but said that they voted the way they wanted; three of those voters voted for Mr. Phelps, two did not. As to the vote-buying scheme (there were other issues in the case), the Louisiana Court of Appeal said that the plaintiff …must show at least that because of fraud or irregularities, the outcome of the election is impossible to determine. Thus, it is the effect of the irregularity on determining the outcome rather than the fact of an irregularity by itself, that guides us in these matters. Accordingly, we conclude that a vote should not be cast out simply because a voter was offered a bribe, or even because a voter accepted something of value for the vote, provided that voter still voted the way he originally intended. Regardless of criminal implications, our focus is on whether the alleged activities actually changed the result of the election by changing the vote totals, or at least made the election result impossible to determine. Based on this record, no more than two votes would be subtracted, a difference that would be insufficient to change the election result or make it impossible to determine. At 357 (emphasis supplied). Jernigan and Nugent, then, illustrate the manner in which ballots are treated when the irregularity in an election is caused by fraud, as contrasted with Boardman, Mirlisena, Pullen and Green where the irregularity was caused by an inadvertent failure to follow the correct statutory procedures. Jernigan illustrates the principle that: 1. when ballots have been illegally cast, and 2. the court cannot determine for whom those ballots were cast, and 3. the entire election is tainted with fraud, the court will void the election and may require that it be run again. 106